Burt v. Board Of Trustees Of The University Of Rhode Island

523 F. Supp. 3d 214 (2021)

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Nature of the Case

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Facts

URI is a public research university with over 2,000 graduate and 14,000 undergraduate students. D traditionally offers both in-person and online learning options, at different price points. The COVID-19 pandemic interrupted the latter option. In March 2020, in-person classes were changed to online-only, students were mostly required to vacate their dormitories, and on-campus services and activities were canceled. Ps were forced to complete their Spring 2020 semesters remotely. URI offered a 25% refund towards housing and meal plans but otherwise declined to refund tuition and other fees. Ps claim this decision amounted to a breach of contract and unjust enrichment. The same fact pattern is true for the other university defendants. Ds moved, pursuant to Fed. R. Civ. P. 12(b)(6), to dismiss the claims brought against them. Ps had brought breach of contract claims against Ds alleging that their decisions to transition from in-person to online education breached their contracts with students. Ds argue that the complaints failed to sufficiently allege contractual promises for in-person education. Ds also argue that Ps are effectively bringing educational malpractice claims - impermissibly asking this Court to assess the quality of their educational offerings.